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MultiPoint Newsletter - Sept 2010 Issue

RF/EMC Regulatory Update

for the United States, Canada & European Union

Dear Colleague,


We have provided typical questions and answers that represent in most cases technical opinions with justification in FCC and CE requirements. The particulars of the product for certification must be considered with respect to the applicability of these questions and answers. We hope you find our update valuable and welcome your feedback if you have any special needs or questions. Call us at 703-689-0368 for your testing requirements. You can view archived issues of MultiPoint at our .

FCC Rules for Lighting Devices

QUESTION: We have designed a 40 KHz switching power supply to power only an LED lamp for lighting purposes。 Is such a lamp/switching power supply considered RF lighting under FCC Part 18?

ANSWER: The device you describe is a Part 15B device. Lighting devices that use a switching power supply operating over 9000 cycles per second to convert 60 Hz AC to DC, or that contain digital logic (as defined in Section 15.3), are regulated under Part 15. Verification would be the appropriate equipment authorization procedure. With RF, pulsing or non-rectified RF signals are applied within the device directly to non-gas lighting components (LED-incandescent), resulting in a Part 15 unintentional device.

Part 18 RF lighting devices use RF frequency to excite a gas to cause the light by applying RF inside the device, locally to electrodes or locally inductively coupled to resonant gas cavities。 Part 18 requires that consumer equipment of this type is subject to either Declaration of Conformity or Certification, and industrial (non-consumer) equipment requires Verification。

On the other hand, if this were an RF lighting device under the rule FCC Part 18。203(a), the device would have to be authorized as consumer ISM equipment unless otherwise specified under either the Declaration of Conformity or Certification procedure prior to use or marketing。

Note that you as the manufacturer, and/or your test lab may choose which authorization procedure to use (DoC or Certification) for consumer RF lighting devices. Each route requires different labeling, but you the manufacturer may decide the route to compliance.

Note that if the device only requires Verification, the specific labeling requirements for this must be followed; the DoC or Certification requirements will not apply.

Radiated tests may be omitted when the operational frequencies of the RF lighting device are less than 1.705 MHz, based on the table in FCC Section 18.309. This is because RF lighting devices only require radiated measurements greater than 30 MHz, and the table in FCC Section 18.309 does not require measurements of radiated emissions if the frequencies are less than 1.705 MHz.

FCC Testing of DTS Devices to Part 15.247

QUESTION: We manufacture DTS devices for certification to Part 15.247. Our designs incorporate two external inline coaxial cable filters as part of the antenna design for each respective frequency. The radio units, filter, coaxial cable/antenna assemblies are identical. Our clients typically get one or the other, depending on their orders. Can we certify both filter antenna assemblies under one FCC Identifier?

ANSWER: You can certify your radio under one FCC identifier. The test report must contain data for both the 5,740 MHz filter antenna assembly and data for the 5,770 MHz filter antenna assembly, including full technical details for both filters. Please note that it is not possible to add a third filter option to the certification at a later date using the FCC Class 2 Permissive change policy. A third filter/frequency option would constitute a new FCC Identifier in accordance with FCC 47 CFR .

FCC Rule Changes for GMRS Devices

QUESTION: We manufacture GMRS radios and recently received notice that the FCC is proposing several rule changes to its present GMRS rules. Is voice scrambling going to be allowed for a GMRS device?

ANSWER: The FCC released a NOTICE OF PROPOSED RULE MAKING AND MEMORANDUM OPINION AND ORDER ON RECONSIDERATION on June 1, 2010 and released it for public comment on June 7, 2010. Several changes are proposed, but to address your question, voice scrambling would not be allowed. The existing wording in the FCC's rule, Section 95.181(e) states that all messages must be in plain language "without codes or hidden meaning", this wording leaves some to believe that voice scrambling is allowed, when it is not.

Furthermore, Section 95。183(a)(4) prohibits a station operator from communicating "coded messages or messages with hidden meanings"。 Voice scrambling by a GMRS device is a method of encoding a message so that the message's meaning (content) is hidden from operators of certain other GMRS devices。 Therefore, it is prohibited to use any type of technique such as scrambling, encryption, inversion, or masking that hides, obscures, or confuses the voice message such that it cannot be readily understood by any listener with any GMRS device designed to receive the transmitted emission type。 See Section 95。631(a), (e), and (f) for permitted emission types and emission limits。

For further information on the proposed changes, see 

A good summary of the FCC's proposed rules can be found at buytwowayradios.com blog.].

FCC Permissive Change Rules for PTT Radio

QUESTION: We have a Part 90 and Part 101 Push-to-Talk radio (PTT) already certified and we would like to apply for a Class 2 Permissive Change based only on firmware changes, there are no hardware changes, and certify to Part 24 rules and regulations。 We are seeking your opinion on the following changes:

  1. Add new emission designators to our existing frequency bands.
  2. Add the bands 930-931 MHz and 940-941 MHz to our present certification.

ANSWER: The FCC does not allow changes to the equipment classification of a certified product。 Your request would be considered a new equipment classification and would require a new FCC Identifier。 The changes you seek are fraught with problems, including at a minimum:

  1. The requested bands require certification to Part 24.
  2. You cannot utilize the Permissive Change policy to create a new composite PCB equipment code grant。

The FCC's Permissive Change Policy, , Section 4(a) clearly explains the allowable changes for approved Non Software Defined Radios.

STANDARDS UPDATE

EU: NEW CENELEC STANDARDS RECENTLY RELEASED This is a shortened list of the CENELEC standards published during the past month:

  • EN 60745-2-17:2010 (9/10/2010) Hand-held motor-operated electric tools - Safety -- Part 2-17: Particular requirements for routers and trimmers
  • EN 80601-2-30:2010 (9/10/2010) Medical electrical equipment -- Part 2-30: Particular requirements for the basic safety and essential performance of automated non-invasive sphygmomanometers
  • EN 60335-2-90:2006/A1:2010 (9/10/2010) Household and similar electrical appliances - Safety -- Part 2-90: Particular requirements for commercial microwave ovens
  • EN 50159:2010 (9/17/2010) Railway applications - Communication, signalling and processing systems - Safety-related communication in transmission systems
  • EN 62479:2010 (9/17/2010) Assessment of the compliance of low power electronic and electrical equipment with the basic restrictions related to human exposure to electromagnetic fields (10 MHz to 300 GHz)
  • EN 60335-2-76:2005/A12:2010 (9/24/2010) Household and similar electrical appliances - Safety -- Part 2-76: Particular requirements for electric fence energizers
  • EN 60335-2-77:2010 (9/24/2010) Safety of household and similar appliances -- Part 2-77: Particular requirements for pedestrian-controlled walk-behind electrically powered lawn mowers

EU: NEW IEC STANDARDS RECENTLY RELEASED This is a shortened list of the new IEC standards published during the past month:

  • CISPR 16-SER (8/23/2010) Specification for radio disturbance and immunity measuring apparatus and methods - ALL PARTS
  • CISPR 16-2-3 (8/23/2010) Specification for radio disturbance and immunity measuring apparatus and methods - Part 2-3: Methods of measurement of disturbances and immunity - Radiated disturbance measurements
  • IEC 61000-4-15 (8/24/2010) Electromagnetic compatibility (EMC) - Part 4-15: Testing and measurement techniques - Flickermeter - Functional and design specifications
  • IEC 61000-4-11 Corr.I1 (8/27/2010) Interpretation Sheet 1 - Electromagnetic compatibility (EMC) - Part 4-11: Testing and measurement techniques - Voltage dips, short interruptions and voltage variations immunity tests
  • IEC 61967-6 Corr.1 (8/30/2010) Corrigendum 1 - Integrated circuits - Measurement of electromagnetic emissions, 150 kHz to 1 GHz - Part 6: Measurement of conducted emissions - Magnetic probe method
  • IEC 61000-4-20 (8/31/2010) Electromagnetic compatiility (EMC) - Part 4-20: Testing and measurement techniques - Emission and immunity testing in transverse electromagnetic (TEM) waveguides
  • IEC 62376 (9/16/2010) Maritime navigation and radiocommunication equipment and systems - Electronic chart system (ECS) - Operational and performance requirements, methods of testing and required test results
  • IEC 60601-2-52 Corr.1 (9/22/2010) Corrigendum 1 - Medical electrical equipment - Part 2-52: Particular requirements for the basic safety and essential performance of medical beds

EU: NEW ETSI STANDARDS RECENTLY RELEASED This is a shortened list of the new ETSI standards published during the past month:

  • (August 2010) Electromagnetic compatibility and Radio spectrum Matters (ERM); Short range devices; Radio equipment to be used in the 1 GHz to 40 GHz frequency range; Part 2: Harmonized EN covering the essential requirements of article 3。2 of the R&TTE Directive
  •  (August 2010) Electromagnetic compatibility and Radio spectrum Matters (ERM); A guide to the production of Harmonized Standards for application under the R&TTE Directive
  •  (September 2010) Electromagnetic compatibility and Radio spectrum Matters (ERM); Peer-to-Peer Digital Private Mobile Radio; Part 1: Conformance testing; Protocol Implementation Conformance Statement (PICS) proforma
  •  (September 2010) Electromagnetic compatibility and Radio spectrum Matters (ERM); Peer-to-Peer Digital Private Mobile Radio; Part 2: Conformance testing; Test Suite Structure and Test Purposes (TSS&TP) specification
  •  (September 2010) Electromagnetic compatibility and Radio spectrum Matters (ERM); Peer-to-Peer Digital Private Mobile Radio; Part 3: Requirements catalogue
  •  (September 2010) Electromagnetic compatibility and Radio spectrum Matters (ERM); Peer-to-Peer Digital Private Mobile Radio; Part 4: Conformance testing; Abstract Test Suite (ATS)
  •  (September 2010) Electromagnetic compatibility and Radio spectrum Matters (ERM); Peer-to-Peer Digital Private Mobile Radio; Part 5: Interoperability testing; Interoperability Test Suite Structure and Test Purposes (TSS&TP) specification
  •  (September 2010) Electromagnetic compatibility and Radio spectrum Matters (ERM); Peer-to-Peer Digital Private Mobile Radio; Part 6: Interoperability testing; Test Descriptions (TD)
  •  (September 2010) Electromagnetic compatibility and Radio spectrum Matters (ERM); VHF radiotelephone equipment for general communications and associated equipment for Class "D" Digital Selective Calling (DSC); Part 2: Harmonized EN covering the essential requirements of article 3.2 of the R&TTE Directive
  • (September 2010) Electromagnetic compatibility and Radio spectrum Matters (ERM); VHF radiotelephone equipment for general communications and associated equipment for Class "D" Digital Selective Calling (DSC); Part 3: Harmonized EN covering the essential requirements of article 3.3(e) of the R&TTE Directive

CANADA: RELEASE OF SRSP-310.5, ISSUE 2 On August 28, 2010, Industry Canada released Notice No. SMSE-014-10 - Release of .

CONTACT RHEIN TECH FOR YOUR FCC AND INTERNATIONAL REGULATORY APPROVALS Rhein Tech Laboratories' worldwide homologation services offer the best strategy for gaining product approval in a large number of target countries。 In addition, we reduce the number of emissions, immunity, and product safety tests required by defining the minimum subset of regulatory standards at the onset, thus reducing the time and cost to enter multiple target countries。 We offer research and approvals in over 50 countries。

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RTL has provided EMC compliance engineering & testing services since 1988 and has a superior reputation with both the Federal Communications Commission and others in the industry。 RTL provides testing services to meet the emissions, immunity, and safety requirements of the European EMC Directive and the EU R&TTE Directive, all FCC rules and regulations, VCCI (Japan), ACMA (Australia), and other international standards。

 

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